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WESH UK is committed to protecting your personal data and respects your privacy.
Our privacy policy informs you about your privacy rights and how the law protects you. It also set’s out how we look after your personal data when you use our website regardless of how.
1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how WESH UK collects and processes your personal data through your use of our website(s), including any data you may provide through our website(s) when you sign in to your client area or purchase a product/service.
When we collect, use and are responsible for certain personal information about you, (until 11pm on 31st December 2020) we are regulated under the General Data Protection Regulation (“GDPR or EU GDPR”) which applies across the European Union (including in the United Kingdom). We are also regulated under the Retained General Data Protection Regulation (“GDPR” or “UK GDPR”) in the United Kingdom from the end of the Brexit implementation period. We are responsible as “controller” of that personal information for the purposes of those laws as described above.
Our website(s) are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements any other notices and is not intended to override them.
1.2 Controller & Data Processor
WESH UK is the controller and data processor and we are responsible for your personal data (collectively referred to as WESH UK “we”, “us” or “our” in this privacy policy).We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3 WESH UK Contact details
Name:
Richard Wraith (Data privacy manager)
Postal address:
53 Links View Road
Croydon
London
CR0 8ND
Telephone number:
0800 5 999 404
Email:
post@wesh.uk
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.4 Changes to the privacy notice and your duty to inform us of changes
The data protection laws changed on 25th May 2018. It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
1.5 Third-party links
Our website(s) may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website(s), we encourage you to read the privacy policy of every website you visit.
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
2.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.5 If you fail to provide data:
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
3.1 Direct interactions
You may give us your Identity, contact and financial data by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes the personal data you provide when you:
3.2 Automated technologies or interactions.
As you interact with our website(s), we may automatically collect technical data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
3.3 Third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources as set out below:
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than to respond to an enquiry you make to us via our website where by making the enquiry you consent to us using any personal data provided for the purposes of dealing with and responding to that enquiry, or in relation to sending third party direct marketing communications to you via e-mail or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
4.2 Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including the basis of legitimate interest |
|---|---|---|
| To register you as a new customer. | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges. (b) Collect and recover money owed to us. |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy. (b) Asking you to leave a review or take a survey. |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and our website(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To deal with a general enquiry or careers enquiry. | (a) Identity (b) Contact |
(a) Consent (b) Necessary for our legitimate interests (recruitment and to communicate with our customers, partners and other third parties) |
4.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
4.4 Promotional offers from us:
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
4.5 Third-party marketing
We will never share your personal data with any company outside of WESH UK for marketing purposes.
4.6 Opting out
You can opt-out of marketing messages from your client area at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
4.7 Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
4.8 Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so (Such as recommending your services to others).
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5.1 We may have to share your personal data with the parties set out below for the purposes:
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
5.3 We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6.1 We share your data within WESH UK including any of our subsidiary companies and on occasion with third party suppliers where required and listed specifically within our Glossary. This might involve transferring your data outside the United Kingdom (UK) or European Economic Area (EEA).
6.2 Some of our external third parties are based outside the UK and/or European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK / EEA. Whenever we transfer your personal data out of the UK / EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are implemented:
We ensure your personal data is protected by requiring all our third parties to follow the same rules when processing your personal data. These rules are either the SCC, as described later in this clause 6, or are “binding rules”.
6.3 If, in the course of providing the services, you are a controller and we are your processor in respect of any personal data, and the United Kingdom is or becomes a “third country” for the purpose of Chapter V of Regulation 2016/679, unless and until such time as the European Commission has decided that the United Kingdom ensures an adequate level of protection for the purposes of Chapter V of Regulation 2016/679, we and you shall, in respect of any transfer of Personal Data subject to Chapter V of Regulation 2016/679 which is neither on the basis of an adequacy decision nor subject to any of the permitted derogations set out in that Chapter V, enter automatically into the Standard Contractual Clauses for the transfer of personal data to processors established in third countries (controller to processor transfers) approved by the European Commission by Commission Decision 2010/87/EU, currently available at https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32010D0087
For the purposes of any standard contractual clauses which we enter into with you by virtue of clause 6.3, we are the “data importer” and you are the “data exporter”, we will process the personal data only for the purpose of providing the services. The data subjects are anyone whose personal data you include in the data you upload to the Services, most probably your staff or your users, or people linked with your users. The Personal Data transferred, including any special categories of data, are decided solely by you. You confirm that you will inform us prior to any data transfer if you feel that the jurisdiction the data is being transferred to is a jurisdiction where the data subjects’ rights are not enforceable (where rights such as access, rectification and deletion are undermined) and effective legal remedies (particularly in case of access to data by public authorities in the recipient country) are not essentially equivalent. We will also keep this situation under regular review in order to ensure we only transfer data to countries where their laws that impose requirements to disclose personal data to public authorities are limited to what is necessary and proportionate in a democratic society.
6.4 If, in the course of providing the Services, you are a controller and you transfer personal data to us as a controller, and the United Kingdom is or becomes a “third country” for the purpose of Chapter V of Regulation 2016/679, unless and until such time as the European Commission has decided that the United Kingdom ensures an adequate level of protection for the purposes of Chapter V of Regulation 2016/679, we and you shall, in respect of any transfer of personal data subject to Chapter V of regulation 2016/679 which is neither on the basis of an adequacy decision nor subject to any of the permitted derogations set out in that Chapter V, enter automatically into the standard contractual clauses for the transfer of personal data from the community to third countries (controller to controller transfers) annexed to the European Commission Decision 2004/915/EC (Set II), currently available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004D0915
For the purposes of any standard contractual clauses which we enter into with you by virtue of clause 6.4, we are the “data importer” and you are the “data exporter”, and we both elect option (iii) (the data processing principles set forth in Annex A) for the purpose of clause II(h). We will process the personal data only for the purposes set out in this privacy policy. The data subjects are anyone whose personal data is provided to us during account registration, most probably your staff. The personal data transferred concerns basic personal details, contact information, data related to your staff’s internet connectivity (in the form of IP addresses) and if you contract with us as an individual, your payment information. We do not collect any sensitive data. You confirm that you will inform us prior to any data transfer if you feel that the jurisdiction the data is being transferred to is a jurisdiction where the data subjects’ rights are not enforceable (where rights such as access, rectification and deletion are undermined) and effective legal remedies (particularly in case of access to data by public authorities in the recipient country) are not essentially equivalent. We will also keep this situation under regular review in order to ensure we only transfer data to countries where their laws that impose requirements to disclose personal data to public authorities are limited to what is necessary and proportionate in a democratic society.
6.5 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA, see contact details for the Data Privacy Manager at section 1 of this Privacy Policy.
7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.1 How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 6 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see request erasure below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us.
9.2 No fee usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
10.1 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
10.2 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
10.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
10.4 External Third Parties
| Name | Type of service | Data Processed |
|---|---|---|
| Slack Inc. | Live Chat Service | Identity Data, Contact Data, Technical Data, Profile Data |
| Google (Analytics, Tag Manager; etc) | Cloud based analytics | Usage Data, Transaction Data, Aggregated Data. |
| Enom Inc. | Domain Name Services | Identity Data, Contact Data. |
| Nominet | Domain Name Services | Identity Data, Contact Data. |
| OpenSRS | Domain Name Services | Identity Data, Contact Data. |
| MaxMind Inc. | Fraud Prevention | Identity Data, Contact Data, Transaction Data, Technical Data |
| Opayo / SagePay | Payment Processor | Identity Data, Contact Data, Financial Data, Transacation Data, Technical Data, Profile Data. |
| PayPal | Payment Processor | Identity Data, Contact Data, Financial Data, Transacation Data, Technical Data, Profile Data. |
| Xero Limited | Accountancy Software | Identity Data, Financial Data, Transacation Data |
10.5 We use Opayo/SagePay for payment services. Opayo / SagePay collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Opayo / SagePay and read their privacy policy at https://www.opayo.co.uk
YOUR LEGAL RIGHTS
10.6 You have the right to: